20241022Compliance Filing 2024 Net Metering.pdf

_ ROCKY MOUNTAIN 1407 W.North Temple,Suite 330
POWER. Salt Lake City,UT 84116
A DIVISION OF PACIFICORP
RECEIVED
Tuesday, October 22, 2024
October 22, 2024 IDAHO PUBLIC
UTILITIES COMMISSION
VIA ELECTRONIC DELIVERY
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd
Building 8 Suite 201A
Boise, ID 83714
RE: COMPLIANCE FILING IN CASE NO.PAC-E-16-07
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER
REQUESTING AUTHORITY TO MODIFY ELECTRIC SERVICE SCHEDULE 135 —
NET METERING SERVICE
Attention: Commission Secretary
Pursuant to Order No. 33511 in the above referenced matter Rocky Mountain Power hereby
respectfully submits its 2024 Annual Net Metering report to the Idaho Public Utilities
Commission.
Informal inquiries may be directed to Mark Alder, Idaho Regulatory Manager at(801) 220-2313.
Very truly yours,
Joe teward
Senior Vice President, Regulation

ROCKY MOUNTAIN POWER'S
ANNUAL CUSTOMER GENERATION REPORT
OCTOBER 22, 2024
Rocky Mountain Power(the "Company"), pursuant to Order No. 33511,1 hereby provides
the 2024 Customer Generation report to the Idaho Public Utilities Commission (the
"Commission").The report provides: customer participation by resource type,nameplate capacity,
total customer generation, and the amount customer generators mitigated the system coincident
peak. The Customer Generation report compares the value of exported generation from customers
with on-site generation to alternative sources of power and summarizes the impacts of customers
with on-site generation to customers without on-site generation.
The Company continues to witness growth of customers installing on-site generation and
has identified quantifiable cost shifts occurring within the residential and Schedule 23 customer
classes between customers with on-site generation and standard service customers due to the
structure of the net metering and net billing programs.
CUSTOMERS WITH ON-SITE GENERATION
Rocky Mountain Power, as of September 30, 2024, had 1,452 customers participating
under Electric Service Schedule No. 135 — Net Metering Service, ("Schedule 135") and 1,527
customers on Electric Service Schedule 136 — Net Billing Service, ("Schedule 136"), with a
cumulative nameplate capacity of approximately 26.4 megawatts ("MW"). This represents a 13
percent increase in customer participation and 15 percent increase in installed capacity since the
2023 On-Site Generation report. There are 2,892 residential customers with a combined on-site
generation name-plate capacity of 24.2 MW and 87 non-residential customers with approximately
2.1 MW of combined name-plate capacity interconnected to the system. Participation in these
'In the Matter of the Application of Rocky Mountain Power Requesting Authority to Modify Electric Service
Schedule 135—Net Metering Service,Case No.PAC-E-16-07.
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programs has increased from 2,646 customers in September 2023 to 2,979 customers by September
2024. The growth in customers' connected capacity with on-site generation is summarized by year
in the following table.
Rocky Mountain Power -Idaho Cumulative Total
Total Residential Non-Res Residential Non-Res Total
Date Customers Customers Customers Size kW Size k Size kW
Dec 2015 156 133 23 646 357 1003
Sep 2016 201 177 24 952 387 1339
Sep 2017 294 269 25 1584 396 1980
Sep 2018 592 560 32 3680 550 4230
Sep 2019 1025 990 35 6656 583 7239
Sep 2020 1362 1312 50 9579 983 10562
Sep 2021 1593 1543 50 11614 963 12577
Sep 2022 1935 1881 54 14729 1046 15775
Sep 2023 2646 2568 78 21233 1756 22989
Sep 2024 2979 2892 87 24250 2142 26392
Customers with on-site generation continue to increase year-over-year with 333 customers
added in the last year. This accounts for more than 10 percent of all on-site customers on the
system. Solar-based technology makes up 99 percent of customer-owned generation systems
compared to 47 percent at the beginning of 2015. There is a current connected capacity of 21,701
kW of solar and an additional capacity of 4,372 kW from solar and battery systems. There is 247
kW of wind, and 72 kW mixed wind and solar, as summarized in the following graph:
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Idaho kW by Resource Type
72
4,372
247
"Ilk
1rr*
21,701
■ Mixed ■Solar ■Wind ■Solar&Battery
CUSTOMERS' ON-SITE GENERATION REDUCTION TO COINCIDENT PEAK
During calendar year 2023, PacifiCorp's system peak of 10,802 MW occurred on August
15, 2023, at hour ending 5 p.m. Mountain Standard Time. Idaho load contributed 509 MW to that
coincident peak. On-site generation reduced Idaho's contribution to the coincident peak by 6.7
MW, or approximately 1.31 percent. The following table summarizes customers' on-site
generation by month and the corresponding reduction to Idaho's contribution to the monthly
system coincident peaks:
PACIFICORP-IDAHO CUSTOMER GENERATION
REDUCTION TO 2023 SYSTEM COINCIDENT PEAK(AT INPUT kW)
Month Jan-23 Feb-23 Mar-23 Apr-23 May-23 Jun-23 Jul-23 Aug-23 Sep-23 Oct-23 Nov-23 Dec-23
PeakDate 30 2 6 3 19 30 21 15 8 30 28 18
Peak Hour(Ending)MST: 10 9 9 9 17 18 18 17 17 8 9 19
Private Generation
Sch 001 Solar 1,270 211 1,191 856 5,572 3,511 49958 59493 79591 19722 19677 0
Sch 001 Wind 55 23 14 51 65 16 29 56 15 38 10 7
Sch 023 Solar 83 14 76 55 351 220 307 346 469 106 103 0
Sch 023 Wind 12 5 3 11 15 4 7 12 3 9 2 2
Sch 006 Solar 28 5 25 18 114 70 97 106 144 32 31 0
Sch 006 Wind 1 1 0 1 1 0 1 1 0 1 0 0
Sch 010 Solar 7 1 6 4 27 17 23 114 155 35 34 0
Sch 036 Solar 93 16 93 74 518 333 493 542 773 181 179 0
TOTAL 1,549 275 15409 15070 65664 45170 55914 65670 95150 25124 25036 9
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TOTAL CUSTOMER ON-SITE GENERATION
During calendar year 2023, Rocky Mountain Power's Idaho customers with on-site
generators produced 31.0 GWh of energy which is summarized by month by customer class in
the following table:
PACIFICORP ELECTRIC OPERATIONS
2023 KWH AT INPUT
PRIVATE GENERATION -STATE OF IDAHO
Month Jan-23 Feb-23 Mar-23 Apr-23 May-23 Jun-23 J4-23 Aug-23 Sep-23 OM-23 Nov-23 Dec-23
Private Generation
Sch 001 Solar 797,101 1,157,223 2,131,932 2.396,065 2,955,864 3,084,532 3,232,011 3,029,809 2,653,379 2,188,661 L324,766 957,857
Sch 001 Wind 13,323 21�251 16,397 23,204 16,674 16,920 12,785 11,917 11,781 16,121 11,384 9,887
Sch 023 Solar 52,301 74,088 135,966 153284 186,334 193,397 199,951 190,871 164,110 134,930 81,236 59,434
Sch 023 Wind 2,971 4,739 3,657 5,175 3,719 3,774 2,851 2,658 2,627 3,595 2,539 2,205
Sch 006 Solar 17,651 25,003 44,970 49.624 60,323 61,233 63,308 58,365 50,182 40,868 24,605 17,495
Sch 006 Wind 302 482 372 526 378 384 290 270 267 366 258 224
Sch 010 Solar 4,257 6,030 10,946 11,968 14,549 14,769 15,269 62,819 54,012 43,987 26,483 18,830
Sch 036 Solar 58,496 86,199 166,770 206,866 274,922 292,434 321,380 299,029 270,153 230,644 141,561 103,090
TOTAL 946,402 1.375.016 2.510.911 2.846.713 3,512,664 3.667.443 3,84T845 3.655,739 3206,511 2,659,171 L611832 1,169,022
IMPACT ON CUSTOMERS NOT PARTICIPATING IN NET METERING
To estimate the cost shifting that occurs when customer generators are credited at the full
retail rate for energy they export to the grid, the Company compared the credit provided to net
metering customers at the retail rate against the value of the energy exported as was determined
for 2022 in the Company's on-site generation study ("On-site Generation Study") as part of Case
No. PAC-E-23-172. The estimated net metering cost shifting impact is summarized in the table
below:
Estimated Net M tering Cost Shifting and Impacts On Non-Net Metering Customers in 2023
Residential Sch Residential Sch General Service General Service
1 36 Sch 23 Sch 6 Total
Exported Energy(MWh) 11,649 2,879 690 77 15,295
Retail Rate$/MWh $101 $119 $91 $43
Value at Retail Rate $1,180,885 $342,195 $62,738 $3,283 $1,589,101
Export Rate$/MWh $44.6 $44.6 $44.6 $44.6
Value at Export Rate $519,538 $128,386 $30,788 $3,445 $682,157
Estimated Cost Shifting $661,347 $213,810 $31,949 -$162 $906,944
2 See In the Matter of the Application of Rocky Mountain Power to Complete the Study Review Phase of the Study of
the Costs and Benefits of On-site Customer Generation,Case No.PAC-E-23-17,Attachment 1 -On-Site Generation
Study Table 4.1 (4.46 cents/kWh in 2022).
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The retail rate that was credited to residential customers for exported energy is on average about
$101 per MWh for Schedule 1 and about $119 per MWh for Schedule 36. For general service
Schedule 23 customers, who are not subject to a demand charge, exported energy was credited at
a price of about$91 per MWh. The retail price for credits provided was much higher than the value
of the energy that was exported which the Company determined to be about $45 per MWh during
2022, resulting in cost shifting from customer generators to other customers. The overall level of
cost shifting that the Company estimates occurred during 2023 was about $907 thousand.
NET METERING AND NET BILLING PROGRAMS
As shown in the previous section of this report, the current programs for customers with
on-site generation provide greater compensation for energy sent to the grid than what that energy
is actually worth. Customers with on-site generation use the system in a way that is fundamentally
different than other customers. Unlike other customers who only consume energy that is delivered
to them from the energy grid, on-site generation customers may at different times be receiving
energy from the energy grid, consuming their own generation on-site, exporting excess energy
from their on-site generation to the energy grid,or using the Company's system as a virtual battery.
Like with any other customer, the Company allocates its costs based upon the volumes of energy
and the magnitude of demand the Company delivers to on-site generation customers. Inasmuch as
customers with on-site generation consume the energy from their own generation, the profile and
overall quantity of energy delivered to them is reduced and the allocation of costs is also
consequently reduced. The concept of net energy is a billing construct that is used for customers
with on-site generation. Net energy does not reflect these customer's physical time-based
relationship with the energy grid. Even though a customer with on-site generation may produce as
much total energy as that customer consumes over a period of time, in real time that customer still
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relies upon the Company's energy grid to import and export energy,provide voltage support, and
act as a virtual battery to store energy for the customer to use later.
Currently the Net Metering and Net Billing programs compensate customers with on-site
generation that export energy back onto the grid at the full retail energy rate.For smaller customers
such as residential and Schedule 23 customers, most of the fixed costs to pay for and maintain the
Company's system are recovered through these volumetric energy charges. On average, the cost
of service for a residential customer is $120.41 per month, $29.39 or about 24 percent of this value
is energy related. The remaining $91.02 or about 76 percent is fixed and not energy related.3
VALUE OF EXPORTED ENERGY
The value of exported energy from customer on-site generators is not equal to the retail
energy rate. In the On-site Generation Study, the Company estimated that the value of exported
energy during 2022 was $44.6 per MWh.4 Providing customer generators with credits for their
exported energy at a price that reflects the fair value instead of a net energy credit that is priced at
the retail energy rate, which includes fixed costs that are not avoidable with customer generation,
is just,reasonable, in the public interest, and ensures that, over time, customer generators are paid
fairly for the value that they provide.
COMMISSION ORDERS
On August 26, 2020, Order No. 34753 approved a two-phase approach used to process the
Company's application. This approach is designed to solicit and incorporate public feedback at
pertinent stages and ensure a reasonably comprehensive study of the issues is conducted in a
3 See In the Matter of Rocky Mountain Power's Application for Authority to Increase its Rates and Charges in
Idaho, Case No.PAC-E-24-04,Robert Meredith's Exhibit No. 55—Class Cost of Service Study.
n Table 4.1 of the Company's On-site Generation Study.
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credible and fair manner. The order included Attachment A, a list of items to study as the parties
evaluate what the value of customer generated export energy should be.
On October 2, 2020, Order No. 347985 closed Electric Service Schedule No. 135 — Net
Metering Service to new customer participation and authorized implementation of Electric Service
Schedule No. 136 —Net Billing Service effective November 1, 2020, for customers interested in
installing onsite generation. The Company issued a press release summarizing the Commission's
order and sent letters to current Schedule 135 participants notifying them that they are
grandfathered on Schedule 135 for twenty-five years. Bill messages were included on all customer
bills notifying them of the closure of Schedule 135 to new participation,grandfathering of existing
customers, implementation of Schedule 136—Net Billing Service on November 1,2020, directing
customers to the Company's website for more information about the changes and ongoing updates.
On June 29, 2023, the Company submitted an application requesting Commission
acknowledgment of its On-site Generation Study, which evaluates the methods, inputs, and
assumptions for valuing on-site generation that is exported to the grid in Case No PAC-E-23-17.6
On August 8, 2024, the On-Site Generation Study was acknowledged by the Commission as
complying with Order No. 34753 and the Company was ordered to submit an application
requesting changes to the structure and design of its proposed export credit rate within six months.
CONCLUSION
The Company continues to experience growth of customers installing on-site generation,
has identified quantifiable cost shifts occurring between residential and Schedule 23 net metering
'In the matter of the Application of Rocky Mountain Power to close the Net Metering Program to New Service&
Implement a Net Billing Program to Compensate Customer Generators for Exported Generation. Case No.PAC-E-
19-08.
'In the Matter of the Application of Rocky Mountain Power to Complete the Study Review Phase of the Study of the
Costs and Benefits of On-site Customer Generation,Case No.PAC-E-23-17.
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customers and standard service customers. The Company is committed to working with interested
parties to develop an export credit rate that is fair for all customers.
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